Fiscal Misconduct Policy

Savannah State University is committed to maintaining the highest professional standards in its administrative operations, promoting ethical practices among faculty and staff, and ensuring a level of accountability appropriate for a public institution. This policy and related procedures for reporting and resolving, investigation, and resolution of fiscal misconduct are established in order to: protect the assets and interests of Savannah State University, ensure a coordinated approach toward resolution of fiscal misconduct, and encourage compliance with applicable Federal and State laws, Board of Regents and/or University Fiscal policies and procedures.

II. DEFINITIONS

Fiscal misconduct includes, but is not limited to:

a) Embezzlement or misappropriation of University funds, goods, property, services, or other resources;

b) Forgery or unauthorized alteration of financial documents or records;

c) Improper handling or reporting financial transactions;

d) Authorizing or receiving compensation for goods not received or services not performed;

e) Authorizing or receiving compensation for hours not worked;

f) Authorizing or receiving reimbursement for travel related expenses not incurred or not authorized under University policy;

g) Use of University facilities and equipment for personal gain;

h) Any activity of intentional wrongdoing and improper behavior related to University financial matters.

Suspected fiscal misconduct is a reasonable belief or actual knowledge that fiscal misconduct has occurred or is occurring. Failure to show an actual diversion of assets or loss shall not be considered unreasonable.

III. STATEMENT OF POLICY

Fiscal misconduct will not be tolerated. Employees found to have participated in fraudulent fiscal acts and/or gross misconduct will be subject to disciplinary action, up to and including termination, pursuant to personnel policies and rules, or subject to criminal prosecution if in violation of Georgia or federal laws.

RESPONSIBILITY
Administrators and all levels of management are responsible for preventing and detecting instances of fiscal irregularities and related misconduct. In addition, administrators are expected to recognize risks and exposures inherent in their area of responsibility and to be aware of indications of fiscal fraud and related misconduct. All employees play a role by refusing to condone or tolerate fiscal irregularities or related misconduct. The Office of Internal Audit and Advisory Services (web-page address) is responsible for informing faculty, staff and students about avenues for reporting suspected instances of fiscal irregularity of related misconduct and for developing and publishing appropriate investigative procedures for suspected cases of fiscal misconduct.

REPORTING AND INVESTIGATIVE PROCEDURES

A. Administrators, faculty and staff who know or suspect that other employees are engaged in fiscal irregularities or related misconduct have a responsibility to report it to the Office of Internal Audit & Advisory Services. Suspected instances of fiscal irregularities or related misconduct may also be anonymously reported to Savannah State University's Ethics and Compliance Reporting Hotline at 877-516-3462 or via web at https://savannahstate.alertline.com.

B. Any reported fiscal misconduct concerns brought to the Office of Internal Audit & Advisory Services or reported anonymously to the Ethics and Compliance Reporting Hotline will be followed through by the campus triage committee. The triage committee consists of the Director of Internal Audit & Advisory Services, University Counsel, and the Director of Human Resources. The committee will determine to the extent necessary the appropriate review or investigation. The investigative process may include other University employees as needed. The committee may also make a recommendation to seek outside consultation from other University System departments or outside agencies. In all fiscal misconduct related reports, it is the intent of the Office of Internal Audit and Advisory Services to follow Section 16.4 of the Board of Regents Business Procedures Manual. http://www.usg.edu/business_procedures_manual

C. The committee shall promptly inform the President and the appropriate Vice President of the allegations and keep them apprised of the on-going investigations.

D. The director or head of the affected department shall be informed of the allegation by the triage committee. The committee will provide guidance on any immediate personnel actions or procedural changes that may be necessary to proceed with the investigation or protect University resources during the investigation. The committee will keep the director or department head informed of the on-going investigation and its results. At the completion of any investigation, the department director or head is responsible for implementing changes in policy and procedures for improved internal controls to prevent a reoccurrence.

E. The affected director or department head shall not attempt to conduct an independent investigation or audit, nor shall they confront or question the individual(s) accused of misconduct. Rather, the affected director or department head shall cooperate and coordinate with the investigative team.

F. Members of the triage committee and affected department employees shall use discretion and not discuss the circumstances with persons notinvolved in theincident or with persons without essentialneed-to-know.

G. If evidence of alleged fiscal misconduct is found, the individual(s) will be subject to such disciplinary action as may be appropriate under Savannah State University, Board of Regents, and State personnel policies and such civil or criminal actions that may be appropriate.

H. The Office of Internal Audit & Advisory Services should notify the Associate Vice Chancellor of Internal Audit of all employee malfeasance (to include inadvertent misuse of the P-Card).

IV. FREQUENTLY ASKED QUESTIONS & ANSWERS FISCAL MISCONDUCT POLICY

Why do we need a fiscal misconduct policy?
The University System of Georgia, (USG) and Savannah State University, (SSU) are committed to the highest standards of moral and ethical behavior and are continuously monitoring ways to improve internal controls that help manage risks. Therefore, USG implemented a System-wide mechanism (The Network) to help its colleges and universities for reporting suspected instances of fiscal and related misconduct. As part of the implementation process, Savannah State University would like to explicitly establish a written policy, definitions, and investigative procedures, that will help assign responsibility and inform our stakeholders of channels to report concerns to management and the Office of Internal Audit & Advisory Services.

What is fiscal misconduct?
Fiscal misconduct activities are violations of law and Board of Regents and University fiscal policies and procedures. Crimes of fiscal misconduct include fraud, theft, embezzlement, or any other dishonest acts.

Who is responsible for reporting claims of fiscal misconduct?
Management and employees have the responsibility for preventing instances of fiscal irregularities and related misconduct. However, we encourage SSU stakeholders such as students, parents, donors, alumni, vendors, contractors, and others to report concerns directly to management and the Office of Internal Audit. Effective February 2008, reported incidents and items of concerns can be reported anonymously to The Network.

What is The Network?
In February 2008, our institution, along with the USG, contracted with The Network to deliver services like hotlines and claim reporting. By contracting with a separate third party to administer a hotline, it gives SSU the flexibility to provide anonymous online communications and ensure each claim is responded to in an efficient and effective manner.

Where do I go to report suspected fiscal misconduct or an item of concern?
There are many channels to report your concerns. You can directly discuss matters with a supervisor or the campus triage committee. You can also use The Network, which has an online reporting form and hotline. This information is provided through a link on SSU's home page, as well as human resources, public safety, and internal audit websites.

What is the triage committee, and who is on it?
The triage committee consists of the university counsel, director of human resources, and the director internal auditor & advisory services. This committee will receive all reported incidents of concern and determine appropriate follow-up actions.

I m afraid I ll lose my job if I report misconduct of my co-workers! What do I do?
The whistleblower statute, OCGA section 45-1-4, prohibits retaliation against state employees for disclosing a violation or noncompliance with laws, rules, or regulations. The Network will offer methods for anonymous and confidential reporting, as well.

I have a sexual harassment or discrimination complaint; do I report it to the Office of Internal Audit or to The Network hotline?
No. Generally, sexual harassment or discrimination issues should be reported to the University's Equal Employment Opportunity and Affirmative Action Officer at 912-351-3812.

I am concerned that I do not have proper internal controls to manage risks in my department. Who can I ask to help?
The Office of Internal Audit & Advisory Services offers advisory services which can give recommendations to help improve and manage risks within your department.

Will all concerns reported be investigated by the Office of Internal Audit & Advisory Services?
In all cases, the claims reported will be viewed by the campus triage committee to determine the appropriate steps and to ensure follow-up is taken. Depending on the subject and severity of the claim, some claims might be handled administratively and corrected with communications to the appropriate unit head. Other claims might require an investigation by the Office of Internal Audit & Advisory Services.

How do I know my concerns will be considered fairly?
The Office of Internal Audit & Advisory Services is independent, reporting to the president administratively and to the associate vice chancellor and chief audit officer at the Board of Regents. Further, the Office of Internal Audit & Advisory Services follows guidelines outlined in the SSU Audit Charter which states the department will adhere to the Institute of Internal Auditors Code of Ethics".